For the health industry in 2021, change was necessary. In 2022, that change looks to be steadfast and prosperous with a wave of new and cemented policies brought in by the 2022 Medicare Physician Fee Schedule and the American Medical Association CPT Coding Guide.
The 2022 AMA CPT code set includes 405 editorial changes, including 249 new codes, 63 deletions and 93 revisions.¹
More than 40 percent of the editorial changes relate to technology services, signaling a shift toward a more digitized and more accessible health landscape.¹
The following list summarized the changes FQHCs, RHCs and other health organizations looking to provide a more modern, equitable care environment should know. See also in some sections, reimbursement increases or decreases.
Changes and Increased Reimbursement for CCM, Complex CCM and PCM
In the 2022 changes, five new codes have been created for Principal Care Management (PCM) and one new code has been created for Chronic Care Management (CCM). With these new additions, come significant pay increases in the RVUs as well, incentivizing more providers to implement these value-based care practices.
The new PCM codes are as follows:²
- CPT 99424: PCM services furnished by a physician or qualified health professional, greater than or equal to 30 minutes of physician or QHP time per calendar month
- CPT 99425: Each additional 30 minutes of physician or QHP time per calendar month
- Should be listed separately in addition to CPT 99424 for each full 30 minutes beyond the first 30 minutes
Clinical Staff can report the following codes for CPT:
- CPT 99426: The first 30 minutes of PCM services furnished by clinical staff, a physician or QHP; billed per calendar month
- CPT 99427: Each additional 30 minutes per calendar month; staff can list up to two units separately in addition to 99426
CPT 99437: The new CCM code on the books, which bills any subsequent 30 minutes of CCM services in a calendar month, furnished by a physician or non-physician practitioner (NPP). The code is a finalization from the proposed 99X21 code.
What to know:
- This code is structured as an add-on code for CPT 99491, with all other CCM elements being required.
- It can be assumed that 99347 is billable by physician and qualified health professional services, but whether it is billable by clinical staff is still unsettled.
- This time should be spent personally by the physician or QHCP
CCM/PCM Reimbursement Changes
At a Glance: CPT Code Table
|Code||Descriptor||2021 Payment||2022 Payment||Difference|
|99490||CCM, furnished by clinical staff; initial 20 min.||$41.17||$62.16||+$20.99|
|99439||CCM, furnished by clinical staff, each additional 20 min.||$37.69||$47.04||+$9.35|
|99491||CCM, furnished by a physician/NPP; initial 30 min.||$82.53||$83.66||+$1.13|
|99437||CCM, furnished by physician/NPP, each additional 30 min.||N/A||$59.47||N/A|
|99487||Complex CCM, furnished by clinical; staff; initial 60 min.||$91.77||$130.37||+$38.60|
|99489||Complex CCM, furnished by clinical staff; each additional 30 min.||$43.97||$68.51||+$24.54|
|99424||PCM, furnished by physician/NPP; initial 30 min.||$90.37||$80.98||+$9.39|
|99425||PCM, furnished by physician/NPP; each additional 30 min.||N/A||$58.46||N/A|
|99426||PCM, furnished by clinical staff; initial; 30 min.||$38.73||$61.49||+$22.76|
|99427||PCM, furnished by clinical staff; each additional 30 min.||N/A||$47.04||N/A|
|G0511||Care Management for RHCs & FQHCs||$65.24||$76.94||+$11.70|
These increases in service payment are actually an exception to the rule this year. In 2022, reimbursement for most Medicare services will be four percent less than in 2021, but year after year, care management proves to be a fruitful and worthwhile investment.
RPM and RTM: Changes and Additions
Remote Patient Monitoring (RPM) has been a huge player the past two years in delivering comprehensive, patient-centered care. Which is why its spinoff, Remote Therapeutic Monitoring, is such an exciting prospect in 2022. It aims to fill in the gaps RPM leaves behind, giving physicians who can’t normally bill E/M services a chance to do so, while also focusing on non-physiological data.
Here are the following RTM codes and its corresponding payments:⁴
Remote therapeutic monitoring (e.g. respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment
Remote therapeutic monitoring (e.g. respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g. daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
Remote therapeutic monitoring (e.g. respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g. daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
Remote therapeutic monitoring treatment, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
Remote therapeutic monitoring treatment, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes
Source 4: Payments
Source 5: Descriptors
RPM Payment Changes
There’s no doubt RPM has continued to grow in popularity. There will be no changes to existing codes, however the RVU payments for RPM will decrease slightly, which, however, should not discourage physicians from furnishing the beneficial and highly effective service. Here are the following reductions:⁴
|Code||Descriptor||2021 Payment||2022 Payment||Difference|
|99454||Monthly data transmission||$63.16||$54.10||-$9.06|
|99091||Interpretation and analysis ( 30 min. increments)||$56.88||$54.57||-$2.11|
|99457||Treatment management services, furnished by clinical staff; initial 20 min.||$50.94||$48.72||-$2.22|
|99458||Treatment management services, furnished by clinical staff; each additional 20 min.||$41.17||$39.65||-$1.52|
Steadfast Telehealth Flexibilities
Audio-Only Made Permanent for Mental Health Services
CMS has made the use of audio-only modalities for the treatment of mental health a permanent billable service. They were able to do so by adding the word “interactive” to “telecommunications system”. Providers can effectively bill audio-only mental health services under the following conditions:⁶
- The service is furnished to an established patient
- The home is now eligible as an originating site
- There must have been a six-month in-person service provided and a 12-month in-person visit must follow.
- Provider must be able to use live video, but is only using audio-only because the patient chose not to or cannot use live video.
- The provider must use a service-level modifier to explain why audio-only was used. This modifier will be created soon.
Special Notes About Audio-Only for FQHCs and RHCs
This flexibility, now made permanent, also extends to FQHCs and RHCs. CMS was able to do so by changing the definition of a mental health visit which is now defined as:
Encounters furnished through interactive, real-time telecommunications technology when furnishing services for the purposes of diagnosis, evaluation, or treatment of a mental health disorder.
FQHCs and RHCs will be required to use the 95 modifier for live-video interactions, as well as the new service modifier created for audio-only services. These health organizations will still be required to abide by the same 12-month subsequent in-person visit requirement, however limited exceptions can be made when the patient is not receiving these services in their home. RHCs and FQHCs will be paid their regular AIR and PPS rates, rather than the flat rate created during the PHE.⁶
For more details on mental health, audio-only allowances, see the Center for Connected Health Policy Factsheet.
Communications Technology-Based Services
While not quite considered telehealth, CTBS services allow providers to provide services that wouldn’t normally be delivered in person, such as the monitoring and analysis of blood pressure measurements. What’s interesting to note is that this could be considered a loophole for providers having difficulties getting reimbursed for RPM.
In 2022, CMS made permanent code G2252.
According to CCHP: “G2252 is defined as a brief communication technology- based service, virtual check-in service, by physician or other qualified health care professional who can report E/M services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment, 11-20 minutes of medical discussion – finalized and allow. There is a direct crosswalk with CPT Code 99442.” ⁶
Need a Partner to Help Work Out Your FY2022?
With these new changes, surely come more questions on what new or existing services to take a chance on. As experts in care management and RPM, Certintell is here to help navigate what services are best for your organization (patients included). Focusing on the underserved, our mission is to help instill value-based care principles from top to bottom, while providing a hands-off approach for your health organization.
SPECIAL NOTE: Updates will come from CMS on CPT Codes throughout 2022, we will update the above as needed.
- American Medical Association. “AMA Releases 2022 CPT Code Set.” American Medical Association, 7 Sept. 2021, www.ama-assn.org/press-center/press-releases/ama-releases-2022-cpt-code-set.
- AAP Division of Health Care Finance. “Coming in 2022: New CPT Codes for Principal Care Management.” American Academy of Pediatrics, 1 Oct. 2021, publications.aap.org/aapnews/news/15666?autologincheck=redirected.
- Taneja, Kaitlyn O’Connor And Reema. “2022 MPFS Chronic Care Management and Principal Care Management Finalized.” Nixon Gwilt Law, 18 Nov. 2021, nixongwiltlaw.com/nlg-blog/2021/11/5/additional-reimbursement-for-chronic-care-management-and-principal-care-management-finalized-in-the-2022-mpfs.
- “2022 Medicare Physician Fee Schedule Final Rule: Increased Reimbursement for Care Management Services.” PYA, 9 Nov. 2021, www.pyapc.com/insights/2022-medicare-physician-fee-schedule-final-rule-increased-reimbursement-for-care-management-services.
- Llp, Foley &Amp; Lardner. “2022 Medicare Remote Therapeutic Monitoring FAQs: CMS Final Rule.” Blogs | Health Care Law Today | Foley & Lardner LLP, 11 Nov. 2021, www.foley.com/en/insights/publications/2021/11/2022-remote-therapeutic-monitoring-cms-final-rule.
- “Final CY 2022 Physician Fee Schedule Fact Sheet.” Center for Connected Health Policy, Nov. 2021, www.cchpca.org/2021/11/CY-2022-Physician-Fee-Schedule-FINAL.pdf.